Legal Opinion
Kenneth Allen Barbara Allen v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided February 6, 1991No. 89-70252PublishedCited by 139 opinions
1Opinion of the Court
WALLACE, Chief Judge:
In 1981, Allen contributed $22,500 of borrowed funds, together with $2,500 of his own money, to a charitable organization. He and his wife then claimed the entire $25,000 as a charitable contribution on their 1981 tax return pursuant to section 170(a) of the Internal Revenue Code (Code), 26 U.S.C. § 170(a). The Commissioner of Internal Revenue (Commissioner) issued a notice of deficiency, denying the Allens’ entire $25,000 deduction and also imposing a negligence penalty under 26 U.S.C. § 6653. Although the tax court ruled that Allen was entitled to a deduction for the…
2Cases cited17 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
- William S. Skeen and Alison Skeen v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989
12 more not listed; retrieve them via the Exa API.
3Cited by139 opinions
- Leo Goldman and Pauline Goldman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1994
- Preben Norgaard Sandra C. Norgaard v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1991
- Jade Trading, LLC ex rel. Ervin Capital, LLC v. United StatesUnited States Court of Federal Claims · 2007
- Gary D. Hansen Johnean F. Hansen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
- Sharon D. Kantor, Robert E. Kantor v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1993
134 more not listed; retrieve them via the Exa API.